The Cannabis Quality series will feature presentations by subject matter experts in the areas of regulations, edibles manufacturing, cannabis safety & quality as well as laboratory testing. The Food Safety Consortium itself is hosted by our sister publication, Food Safety Tech, but the Cannabis Quality series will be co-hosted by Cannabis Industry Journal as well.
Citing the need to address safety in a burgeoning market, Rick Biros, conference director, believes education is key to helping the cannabis industry mature. “As the cannabis industry evolves, so does the need to protect the consumer,” says Biros. “Just as we protect the safety of our food supply chain, it is important to educate the cannabis industry about protecting their supply chain from seed to sale. Through these educational talks, we want to help bridge that gap, hosting a forum for those in the cannabis industry to interact with food safety professionals.”
The 2018 Food Safety Consortium Conference & Expo will be held November 14–16 in Schaumburg, Illinois. The event is a top food safety conference that features Food Safety and Quality Assurance (FSQA) industry experts and government officials.
The conference focuses on food safety education and networking, providing attendees information on best practices and new technology solutions to today’s food safety challenges. Previous keynote speakers have included food safety leaders such as Stephen Ostroff, M.D., deputy commissioner for Foods and Veterinary Medicine, U.S. Food and Drug Administration and Frank Yiannis, vice president of Food Safety at Walmart and author of Food Safety Culture: Creating a Behavior-Based Food Safety Management System.
Before submitting an abstract, following are a few points to keep in mind:
The abstract should be about 300 words
Presentations will be judged on educational value
Don’t submit a sales pitch!
Presentation time is about 45 minutes—this includes a 10-15 Q&A session
California’s regulated adult use cannabis market has been up and running for around four months now and rumors of a potential supply bottleneck on the horizon are beginning to circulate. There are a number of factors that could have an impact on the cannabis supply in the market, most of which stem from changes in the distribution channels now that the state is implementing new regulations.
Those include a slow rollout in licensing cannabis businesses, new testing requirements, the supply carryover period prior to January 1stas well as new labeling and packaging regulations. In this piece, we are going to examine some of those rumors, see if there might be some truth to them and provide some guidance for what businesses can do to prepare for this.
A Slow Start to Licensing
This one is perhaps the most obvious factor to impact the supply chain in California. Much of the delays in licensing cannabis businesses came from the issue of local control, where businesses needed to get approval from their municipality before getting a state license. In the first month of the new market, it took Los Angeles weeks longer than other counties to begin licensing dispensaries. Whereas San Diego retailers saw a massive influx of customers right away, forcing them to buy up product to meet the high demand. Smaller producers also had trouble getting licenses as quickly as some of the larger ones.
Basically it all boils down to a slow start for the new market, according to Diane Czarkowski, co-founder of Canna Advisors. “The state is requiring businesses to get their local licenses before they can get their state license and that will create a delay in operators being able to bring products to market,” says Czarkowski. She says this is pretty typical of new markets, or when a market experiences dramatic changes quickly. “It could be a brand-new market, like in Hawaii, where the operators were ready with product, but there were no labs to test the products, which caused delays.” In addition to the licensing roll out being slow to start, the temporary licenses initially awarded to businesses are set to expire soon, by the end of April.
Stricter Rules to Come
The same logic goes for the testing regulations. New testing and labeling requirements, according to the Bureau of Cannabis Control regulating the market, will be phased in throughout 2018.
The state has already phased in cannabinoids, moisture content, residual solvent, pesticide, microbial impurities and homogeneity testing to some extent. On July 1st, the state will add additional residual solvent and pesticide testing as well as foreign material testing. At the end of 2018, they plan on requiring terpenoids, mycotoxins, heavy metals and water activity testing. All of those tests cost money and all of those tests could impact suppliers’ ability to bring product to market. “Oftentimes regulations require different types of testing to be done to products without recognizing that adequately completing those tests requires different methods, equipment, and standards,” says Czarkowski. “Most labs do not have all of the necessary components, and they are very costly. Producers could wait weeks to get test results back before they know if they can sell their products.”
Back when we spoke with Josh Drayton, deputy director of the California Cannabis Industry Association, about the upcoming changes to the California market, he voiced his concerns with the coming testing rules. “A lot of testing labs are concerned they are unable to test at the state’s threshold for some of these contaminants and pesticides; the detection limits seem very low,” says Drayton. “The testing portion will take years to work out, I am sure we will remove and add different pesticides and contaminants to the list.” California’s testing industry is, however, capable of adapting to changing rules, as they’ve done in the past on more than one occasion. It should be noted that many labs in the state are on the cutting edge of testing cannabis, working with The Bureau to implement the new rules.
Cannabis products made prior to December 31st, 2017, did not need to comply with the stricter testing rules that are coming in the next few months. This carryover period allowed dispensaries to have products on the shelves when the new market launched in the beginning of 2018. Retailers knew this rule meant they needed to stockpile product in the event of a supply bottleneck, and it appears much of that product is now sold and running out, according to Roy Bingham, founder and chief executive officer of BDS Analytics. “The true impact of licenses is starting to be felt since the carryover from December buying prior to the licensed market has been sold,” says Bingham. “Some of the major brands have consciously not applied for licenses. Some of that has to do with the flexibility the government has given them to wait.”
A fourth reason for a potential bottleneck could also come from packaging and labeling rules. “There will have to be many modifications to products to ensure they follow the new potency regulations, and many formulations will have to be modified in order to meet new regulations,” says Czarkowski. Distributor licenses, according to The Bureau, have a number of compliance documentation requirements, such as arranging for all product testing, quality assurance and packaging and label accuracy. Everything has to be packaged before it gets to a dispensary, which is a new rule California businesses need to comply with.
Pricing is the Indicator
There are a handful of reasons why prices could increase; some of them are more defined than others, the biggest factor being the tax burden passed on to consumers, where reports showed up to a 40% increase from last year. A price increase in the future could also come from The Bureau implementing testing regulations throughout 2018, as mentioned previously.
If prices were to surge enormously and very quickly, that might be an indicator that a shortage is fast approaching. A dramatic increase in price over this year could squeeze margins for smaller producers, forcing retailers to pass that burden on to consumers as well.“So yes, the rumors are true.”
According to Roy Bingham, there has been a significant increase in pricing in all categories at the retail level. “In January and February, we are seeing about 10% increases per month in average retail prices,” says Bingham. “If we look at concentrates in California during 2017, they averaged about $34 by the end of the year, whereas it was about $31 at the start of 2017. So in January, prices have increased up to $38, which is a bit above trend, but in fact we were seeing a trend upwards before January 1st as well.” Comparing that with edibles pricing, Bingham says we see a clear jump at the start of 2018. “It was basically flat in 2017, averaging $14 roughly almost straight-line across, dipped in December, then in January it jumped to $17 and then to $18 in February, a big increase and significantly more than concentrates,” says Bingham. He also says flower was hovering around $9 per gram in December 2017, but surged above $10 in February 2018.
According to Cannabis Benchmarks, the California wholesale averages surged in the summer of 2017 up to $1,631 by September, then reached their lowest point in December, with their spot index at $1,368. The Cannabis Benchmarks report underlines some important reasons for the changes in pricing, but they also attribute it to the new licensing system.
“Increasing operating expenses for businesses preparing to enter California’s licensed system in 2018 were key to propping up supply side rates in the first six months of 2017. New compliance requirements were being instituted to varying degrees by local governments, while market participants warily eyed draft regulations from state officials for guidance as to how to prepare their sites and facilities to meet under-construction regulatory mandates.”
Their report highlights some very important aspects of the supply chain. “Again, it is likely that the increased costs faced by operators up and down the supply chain exert some upward pressure on wholesale rates, preventing them from steep year-over-year declines that were observed in some of the other major Western markets,” reads the Cannabis Benchmarks report.
So How Can Businesses Prepare?
Well to start, producers should make sure their operations and product are clean and safe. Making sure your product will pass a pesticide test should be top of mind. Dispensaries should also be wise in selecting their suppliers, performing supplier quality audits or some form of verification that they meet your standards is key in a consistent supply chain.
Dr. Jon Vaught, chief executive officer of Front Range Biosciences, believes tissue culture could be a viable solution for some California producers. Using tissue culture, as a form of propagation instead of mothers and clones can be cleaner, cheaper and more efficient, thus allowing growers to keep up with demand and prevent a shortage.
Dr. Vaught says growers could look to tissue culture as a means to “mitigate risk to their supply chain and mitigate the risk of potential loss and improve their ability to efficiently grow their plant.” Maintaining a disease-free, sterile environment is a huge advantage in the cannabis market. “The real use of tissue culture is to provide disease free, clean, certified material, that has gone through a QA program,” says Dr. Vaught. “In greenhouses, the ability to control your environment is also critical because your margin of error is high. Variations in sunlight, weather, humidity all of these things have an impact in your plants. Technology can help monitor this.”
We’ve covered the basics of tissue culture previously on CIJ, with Dr. Hope Jones chief science officer of C4 Laboratories. She echoes many of Dr. Vaught’s points, firmly believing that, having existed for decades, tissue culture is an effective propagation tool for advanced breeders or growers looking to scale up.It is a complex supply chain that requires systems thinking.
It is important to note they don’t think growers should try this at home. Work with professionals, get the necessary funding, the training and facilities required if this is a project that interest you. “There’s a pretty big barrier to entry there,” Dr. Vaught urges. “The ability to manage thousands or millions of plants in a greenhouse increases risk, whereas in the lab, you’ve got a safe, secure, sterile environment, reducing risk of disease, making things easier to manage. The producers most successful at large scale are controlling those variables to the T.”
Ultimately, one segment of the market can’t prevent a bottleneck. It is a complex supply chain that requires systems thinking. Regulators need to work with producers, manufacturers, retailers, distributors, patients, consumers and laboratories to keep an eye on the overall supply chain flow.
Diane Czarkowski says the California market should prepare for this now if they haven’t already. “We have seen supply issues in every market going through a change. Other potential bottlenecks will occur because former distribution channels will be required to change,” says Czarkowski. “So yes, the rumors are true.”
Hazard Analysis and Critical Control Points (HACCP) Defined
Farm-to-fork is a concept to describe the control of food safety starting in the fields of a farm and ending with deliciousness in my mouth. The more that is optimized at every step, the more food safety and quality are realized. Farm-to-fork is not a concept reserved for foodies or “eat local” food campaigns and applies to all scales of food manufacture. HACCP is like putting the last piece of a huge puzzle in the middle and seeing the whole picture develop. HACCP is a program to control food safety at the step of food processing. In states where cannabis is legal, the state department of public health or state department of agriculture may require food manufacturers to have a HACCP plan. The HACCP plan is a written document identifying food safety hazards and how those hazards are controlled by the manufacturer. While there are many resources available for writing a HACCP plan, like solving that puzzle, it is a do-it-yourself project. You can’t use someone else’s “puzzle,” and you can’t put the box on a shelf and say you have a “puzzle.”
HACCP is pronounced “ha” as in “hat” plus “sip.”
(Say it aloud.)
3-2-1 We have liftoff.
The history of HACCP starts not with Adam eating in the garden of Eden but with the development of manned missions to the moon, the race to space in the 1950s. Sorry to be gross, but imagine an astronaut with vomiting and diarrhea as a result of foodborne illness. In the 1950s, the food industry relied on finished product testing to determine safety. Testing is destructive of product, and there is no amount of finished product testing that will determine food is safe enough for astronauts. Instead, the food industry built safety into the process. Temperature was monitored and recorded. Acidity measured by pH is an easy test. Rather than waiting to test the finished product in its sealed package, the food industry writes specifications for ingredients, ensures equipment is clean and sanitized, and monitors processing and packaging. HACCP was born first for astronauts and now for everyone.
HACCP is not the only food safety program.
If you are just learning about HACCP, it is a great place to start! There is a big world of food safety programs. HACCP is required by the United States Department of Agriculture for meat processors. The Food and Drug Administration (FDA) requires HACCP for seafood processing and 100% juice manufacture. For all foods beyond meat, seafood and juice, FDA has the Food Safety Modernization Act (FSMA) to enforce food safety. FSMA was signed in 2011 and became enforceable for companies with more than 500 employees in September of 2016; all food companies are under enforcement in September 2018. FSMA requires all food companies with an annual revenue greater than $1 million to follow a written food safety plan. Both FDA inspectors and industry professionals are working to meet the requirements of FSMA. There are also national and international guidelines for food safety with elements of HACCP which do not carry the letter of law.
The first step in HACCP is a hazard analysis.
Traditionally HACCP has focused on processing and packaging. Your organization may call that manufacturing or operations. In a large facility there is metering of ingredients by weight or volume and mixing. A recipe or batch sheet is followed. Most, but not all, products have a kill step where high heat is applied through roasting, baking, frying or canning. The food is sealed in packaging, labeled, boxed and heads out for distribution. For your hazard analysis, you identify the potential hazards that could cause injury or illness, if not controlled during processing. Think about all the potential hazards:
Biological: What pathogens are you killing in the kill step? What pathogens could get in to the product before packaging is sealed?
Chemical: Pesticides, industrial chemicals, mycotoxins and allergens are concerns.
Physical: Evaluate the potential for choking hazards and glass, wood, hard plastic and metal.
The hazards analysis drives everything you do for food safety.
I cannot emphasize too much the importance of the hazard analysis. Every food safety decision is grounded in the hazard analysis. Procedures will be developed and capital will be purchased based on the hazard analysis and control of food safety in your product. There is no one form for the completion of a hazard analysis.
So where do you start? Create a flow diagram naming all the steps in processing and packaging. If your flow diagram starts with Receiving of ingredients, then the next step is Storage of ingredients; include packaging with Receiving and Storage. From Storage, ingredients and packaging are gathered for a batch. Draw out the processing steps in order and through to Packaging. After Packaging, there is finished product Storage and Distribution. Remember HACCP focuses on the processing and packaging steps. It is not necessary to detail each step on the flow diagram, just name the step, e.g. Mixing, Filling, Baking, etc. Other supporting documents have the details of each step.
For every step on the flow diagram, identify hazards.
Transfer the name of the step to the hazard analysis form of your choice. Focus on one step at a time. Identify biological, chemical and physical hazards, if any, at that step. The next part is tricky. For each hazard identified, determine the probability of the hazard occurring and severity of illness or injury. Some hazards are easy like allergens. If you have an ingredient that contains an allergen, the probability is high. Because people can die from ingestion of allergens when allergic, the severity is high. Allergens are a hazard you must control. What about pesticides? What is the probability and severity? I can hear you say that you are going to control pesticides through your purchasing agreements. Great! Pesticides are still a hazard to identify in your hazard analysis. What you do about the hazard is up to you.
By Brett Giddings, Olivia L. Dubreuil, Esq. No Comments
As with any product, packaging has a vast range of sustainability considerations that should be accounted for in its design, development and use. Often the most visible component of any product, and certainly so for most forms of cannabis products, packaging is a key sustainability issue for the entire cannabis supply chain.
What is sustainable cannabis packaging and what does it look like? This can be a loaded question, but one we can revisit after considering the basic functions of packaging.
Cannabis packaging, and packaging generally, is designed to perform three basic functions: protection, preservation and promotion. If it does not adequately address these three areas then the chance of product failure, loss of consumer trust and increased waste is likely.
Let’s take a high level look at each of these:
Protection: Whilst cannabis is not currently travelling huge distances, like some of the food we consume, protection is key at each point of the supply chain. Inputs into the growing process often come packaged, flowers and such are packaged for shipping and storage, bulk-packaged cannabis is sent to dispensaries, extractors, etc, and ultimately re-packed into what will become the consumer-facing packaging. Importantly for cannabis, it may require an additional level of protection to ensure children are not able to access the contents.
Preservation: Like any consumable item, cannabis has a shelf life, and packaging plays a key role in preserving the usability of the product. Whether it is a chocolate, a cannabis-infused drink, or flowers, it is critical that each product maintains a certain level of quality and consistency.
Promotion: Packaging allows one part of the supply chain to communicate specific elements of a product to those further along the supply chain. The most obvious, and for cannabis probably the most important, is the communication of contents within a packaged item (labeling), such as the percentage of CBD in a gummy or origin of a particular bud. Packaging is also the reflection of a brand, an image.
Taking these basic elements into account, we can apply a framework for designing and choosing more sustainable packaging. This framework for cannabis packaging accounts for and balances four principles: Fit for purpose, efficient, low impact and re-usable.
Fit-for-purpose. Essentially, this involves making sure that the packaging adequately performs the ‘3-Ps’ above. Packaging commonly accounts for less than 10% of the energy inputs that have gone into a complete product (for example, a candy packaged in a foil-lined plastic wrap). If the packaging fails to protect and preserve the candy, then the energy (or the water, the material, the investment) embedded in the product it contains is wasted.
The second principle relates to material efficiency. Once the packaging works, it is then important to minimize material and resource inputs. Effectively designed packaging uses lighter-weight materials and reduced numbers of materials and components. It also reduces air space and maximizes transport yields.
The third principle involves using low-impact materials. Material inputs should come from non-controversial sources, such as verified/certified supply chains and suppliers that have been assessed to ensure appropriate sustainability-related issues are addressed. Wherever possible, consider renewable and recycled-content inputs, and those made using renewable energy.
Finally, cannabis packaging should be re-usable, recoverable and/or recyclable at end of life. Consider materials and design formats that can be reused multiple times, and packaging that can be recycled and composted by consumers in the systems readily available. Linking back to the third ‘P’, Promotion can be used to make sure that your packaging clearly communicates what someone should do with your packaging. If it is recyclable, returnable, reusable or plantable, tell them it is and how to proceed.
Bear in mind that the most sustainable packaging options are often the result of thinking outside the box. The design process of your packaging should include brainstorming and researching outside of your own industry. What are new and innovative solutions, new materials, new ways to think about product conception that could negate the need for unnecessary packaging elements. New and innovative packaging solutions can raise your business’ profile, catch consumers’ attention and attract investors. It showcases your business as a forward-thinking one.
Packaging sustainability can look different for each and every cannabusiness. It is important to make sure that the four principles are part of your packaging selection/design process. As with any other sustainability issue, it is best to start thinking about packaging early on, and considering packaging as a part of the actual product system.
If you are not thinking about packaging sustainability, be assured that regulators, consumers and your industry peers are. Make sure you are driving the discussion about packaging, rather than being driven by those who may not fully understand your packaging needs.
By Olivia L. Dubreuil, Esq., Brett Giddings 2 Comments
Dear Cannabusiness Community,
You may have read our two recent articles. We received so much positive feedback that Aaron Biros (editor-in-chief of Cannabis Industry Journal) has invited us to continue with our own column at CannabisIndustryJournal.com. We are very happy to launch this column, and we thought we would take this opportunity to introduce our project, our vision and ourselves so you can understand where we are coming from when you read this series of articles.
Brett and I both have a background in business sustainability and corporate responsibility. We both have backgrounds in management consulting, with a specific expertise in sustainability issues along the supply chain. We have been working together for almost nine months now on sustainability issues in the Bay Area. In May, we started to get interested in sustainability in the cannabis industry and before we knew it we were diving deep into research relating to the environmental, social and ethical impacts of the legal cannabis industry. It was actually difficult to find a lot of information, as the reign of prohibition still very much influences what is available.
In June, we attended the National Cannabis Industry Association’s conference in Oakland to open up the conversation with cannabis industry players and to find out about people’s attitudes and approach to sustainability. The results were overwhelmingly positive. Not only were we encouraged to launch a project, but also excited to discover that many of the speakers presenting at the conference referenced sustainability in one way or another when they talked about environmental impact awareness, social justice, ethics or about staying competitive when “big business” enters the market.
What started out as a side project quickly became the center of focus this summer when we decided to incorporate Project Polaris, a California non-profit, to deliver sustainability knowledge and expertise to the cannabis industry.
Our thinking is as follows:
Thinking about sustainability, means thinking strategically about business. As we forge a new and upcoming industry, let’s seize the opportunity to make it a sustainability-focused one! Let’s create generally accepted industry principles that fosters a positive image of the industry and teaches newcomers about best environmental and social practices. Let’s create a voluntary and industry-led socially responsible code of conduct for cannabis business owners and suppliers, helping the regulators, as they will be drafting all of the future regulations of the legalized cannabis market. Let’s do more research on the market and the consumer. Let’s develop clean and green alternatives to dirty processes or practices. Let’s elevate the discussion and create a model industry, one where short-term, large-scale, quality-lowering corporate interests are kept at bay.
With this vision in mind, we created Project Polaris because we believe that this is a real opportunity for the industry to be a role model for other industries (and educate legislators as well as drive public opinion in those states that are still under prohibition laws). We believe there is a real economic opportunity for those businesses that understand how to embed sustainability properly within their business model. Because we know that sustainability influences legislators in a positive way because it sheds a positive light on businesses.
In the upcoming months, we will continue to research and report on sustainability-related issues facing the cannabis industry, such as packaging, edibles, “organic” in cannabis, butane extraction versus CO2 extraction and so on. We also welcome questions from our readers. If you have a question, please post it in the comments section below.
We will also take this opportunity to call out to cannabis industry organizations, cannabis businesses, or cannabis related services and product suppliers to get in touch with us if they wish to find out how to integrate sustainability more concretely into their action plan. We are not planning on doing this alone, we are seeking partners to join us on this journey, and we want to partner with you on your journey to Cannabusiness Sustainability.
PS: We still have one seat open for the board of directors and would love to hear from you if you are interested!
By Olivia L. Dubreuil, Esq., Brett Giddings No Comments
Most readers ought to be well aware that the cannabis industry is rapidly growing. The Arcview Group, an Oakland-based investor network, estimates the retail and wholesale cannabis market will reach $22.8 billion by 2020. That number represents a lot of people consuming cannabis in many different ways.
The average cannabis consumer is changing. A new range of social groups is consuming cannabis-based products. From yoga diehards, to middle-aged men and women, veterans that have ‘tried everything else’ and young professionals looking for a different way to relax, the market is broadening.
This new segment of cannabis consumers are often not looking to get high- they are looking for anti-inflammatories, relaxants and ways of dealing with chronic pains and stress. For these health and wellness seekers, the last thing they want is a product dosed with pesticides, insecticides or butane residues. We can expect to see these consumers to follow broader consumption trends- specifically when it comes to a product like cannabis that people are inevitably placing in or on their bodies.
These consumers come with new sets of expectations, similar to those when they buy fruit, vegetables, coffee or chocolate. They are increasingly curious about the contents of the products they purchase- they are a large part of the reason that the sales of organic produce has ‘ballooned’. They are asking questions like: Does the product contain pesticides? Has the product been cultivated in a way that minimizes negative environmental impacts? How do we know that the supply chain quality controls are rigorous enough to ensure no one has tampered with the product? Who is growing and picking this product and how are those people being treated?
When a curious consumer enters a modern American supermarket, they are guided by a range of messages relating to the contents and supply chain that was part of making each product. Organic, non-GMO, pesticide-free, fair trade, free-range and locally produced are some of the common criteria. The more credible labels are supported by codes and procedures in which the whole supply chain is audited, monitored and approved by the certifying body according to certain standards- for example the USDA certifies organic foods.
Being a Schedule I controlled substance under federal law, cannabis is probably not going to receive USDA organic certification any time soon. However there are organizations out there that are committed to increasing the availability of cannabis grown with organic practices. Certifying bodies like Certified Kind and the Organic Cannabis Growers Society are gaining popularity among growers who see the market evolving in that direction. At the same time, businesses such as Delicious Fog (an ‘organic-focussed’ delivery service in Santa Clara County) and Harvest (an ‘organic’ dispensary in San Francisco)- are specializing in the sale of these ‘organic’ cannabis products.
Just like any sustainability issue- ensuring your cannabis product comes from a well-managed supply chain cannot be a last minute add-on. Whether a business is small, large, mature or emerging, developing a strategic approach to the diverse spread of sustainability challenges is critical.
As a cannabis business what can you do to appeal to the new cannabis consumer?
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